- 6 - Petitioners were not entitled to avail themselves of the 150-day filing period. Accordingly, respondent’s motion to dismiss will be granted.3 An appropriate order of dismissal will be entered. 3Petitioners also make a generalized claim that they were denied due process during the partnership level proceeding. The partnership level proceeding preceded and was completed prior to the notices of deficiency upon which the petition in the instant case was based. Our jurisdiction to consider any of petitioners’ arguments must be based upon a timely petition. As we have held, we lack jurisdiction because the petition in this case was not filed within the statutory time limit.Page: Previous 1 2 3 4 5 6
Last modified: May 25, 2011